Updated May 2, 2017
Effective June 2, 2017
Personal Information about representatives of Afiniti’s enterprise clients. We collect Personal Information from representatives of Afiniti’s enterprise clients, such as:
- When client employees are registered for Afiniti Portal access, in which case we may collect the employee’s first and last name, email address, and username and password; and
- When client employees fill out and submit surveys through the Afiniti AIMS Portal, in which case we may collect any information that our clients’ employees voluntarily submit to us.
- Personal Information about website visitors and prospective clients or partners. We collect Personal Information from website visitors and prospective clients or partners who contact us through our website. In this context, we may collect your first and last name, phone number, email address, and any other information that you voluntarily submit to us through our “Contact Us” form or other means of communication.
- Personal Information about prospective employees. We collect information about prospective employees when they submit a job application form on our website. For example, we may collect an applicant’s first and last name, phone number, email address, city and country of residence, and any other Personal Information that the applicant voluntarily submits to us, such as information contained in a cover letter, resume, or curriculum vitae.
Other Information collected via passive collection and tracking technologies. Like most websites, in addition to the Personal Information described above, we also gather certain Other Information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Sites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, general location, and/or clickstream data. We and our third-party service providers may collect such information using the following technologies:
- Server Logs. When you use the Sites, we automatically receive and record certain information from your computer (or other device) and your web browser. To collect such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
- Pixel tags. The Sites may collect information through a “pixel tag” (also known as a “clear gif” or “web beacon”). A pixel tag is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page to transmit information about your use of the Sites.
Afiniti uses the information that it collects for a variety of purposes, including to:
- Provide the services to our clients, administer user accounts, and respond to customer service requests;
- Contact our clients or prospective clients and respond to requests for information about Afiniti;
- Process and evaluate job applications that we receive from prospective employees;
- Administer the Sites, conduct internal auditing, and troubleshoot technical or user issues on the Sites;
- Count and recognize visitors and users of the Sites and analyze how individuals use our services;
- Improve our existing products and services or create new products and services;
- Generate and analyze trends in the aggregate; and
- Comply with legal and/or regulatory requirements.
Afiniti may disclose the information that it collects to third parties for a variety of purposes, such as:
- Legal purposes. We may use or disclose your Personal Information or Other Information to third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable laws or a court order, subpoena, request from government or law enforcement, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate a merger, acquisition, or sale of all or a portion of Afiniti’s assets. You will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
- De-identified or aggregated information. Afiniti also may share de-identified and aggregated information about users of our services, such as by publishing a report on trends in the usage of the Sites; and
- With your consent. We may disclose your information to any other third party with your prior consent.
Afiniti is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. As noted below, Afiniti complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
International Transfers, EU-U.S. Privacy Shield, and Swiss-U.S. Privacy Shield
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afiniti is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afiniti may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Access and Choices
Upon request Afiniti will provide you with information about whether we hold any of your Personal Information. You may request access, correction, or deletion of your Personal Information by contacting us at email@example.com. We will respond to these requests within a reasonable timeframe.
The security of your information is important to us. We use commercially reasonable physical, technical, and administrative safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal Information. If you have any questions about the security of your Personal Information, you may contact us at firstname.lastname@example.org.
If you are a client and would like to update or delete your Afiniti Portal account, please contact us at email@example.com. We will respond to your request within a reasonable timeframe. If you have questions regarding our privacy policies or practices, please contact us at firstname.lastname@example.org. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
For all other inquiries, please visit our contact page or write to us at:
Privacy @ Afiniti
1700 Pennsylvania Avenue
Washington, DC 20006